Law Journal Library - Skip to main content
Content Start

Click here to view short-term subscription options to access this document.

8 Creighton L. Rev. 523 (1974-1975)
Constitutional Law - Standing - Supreme Court Limits Taxpayer Standing - United States v. Richardson, 94 S. Ct. 2940 (1974)

handle is hein.journals/creigh8 and id is 543 raw text is: CONSTITUTIONAL LAW - STANDING - SUPREME COURT LIMITS
TAXPAYER STANDING--United States v. Richardson, 94 S. Ct. 2940
In United States v. Richardson,' the Supreme Court was poten-
tially faced with the question of whether to order the Secretary
of the Treasury to reveal the receipts and expenditures of the
Central Intelligence Agency (CIA). The disclosure issue was never
reached, however, because the plaintiff was denied standing to
assert his claim. In refusing to grant standing, the court seems
to have tightened its standards for taxpayer standing, thus ending
any possibility of an expansion of the class of persons affected.
William  B. Richardson sought an accounting of the receipts
and expenditures of the CIA.2 In essence, he sought to have the
Central Intelligence Agency Act3 declared unconstitutional and to
obtain an order requiring the Secretary of the Treasury to pub-
lish an accounting of the CIA's expenditures. He alleged that Ar-
ticle I, Section 9, Clause 7 of the Constitution [hereinafter referred
to as the Statements and Accounts Clause] mandated such publi-
cation. That provision says:
No Money shall be drawn from the Treasury, but in
Consequence of Appropriations made by Law; and a regu-
lar Statement and Account of the Receipts and Expendi-
tures of all public Money shall be published from time to
Richardson first wrote to the Government Printing Office and
the Treasury Department inquiring about the publication of the
CIA's expenses. Those offices replied that they neither had the de-
sired information nor could they readily obtain it. Consequently,
Richardson commenced this action in the United States District
Court for the Western District of Pennsylvania.4 The trial judge
1. 94 S. Ct. 2940 (1974).
2. A provision of the Central Intelligence Agency Act, 50 U.S.C. §
403f(a) (1970), permits the agency to transfer and receive funds from other
federal agencies with the approval of the Office of Management and Budget
without regard to any provisions of law limiting or prohibiting transfers
between appropriations.
3. 50 U.S.C. § 403(a) et seq. (1970).
4. 465 F.2d 844 (3d Cir. 1972).
Richardson had initiated a similar suit earlier, but it was dismissed for
lack of federal jurisdiction. [Richardson v. Sekel, 409 F.2d 3 (3d Cir.
1969), cert. denied, 396 U.S. 949 (1969).] Id. at 847 n. 1.
The jurisdiction in the present case is based upon the Mandamus and
Venue Act, 28 U.S.C. § 1361 (1970). Id. at 849.

Already a Subscriber?

What Is HeinOnline?

HeinOnline is the world’s largest image-based and fully searchable legal and academic research database. Material contained in HeinOnline is an exact replication of the original printed product, and coverage is typically comprehensive. Contact us today for a free demo of this incredible resource.

We offer annual subscriptions to all HeinOnline collections to universities, colleges, law firms, individuals, and other institutions. To request a quote or trial, please click here.

Please note: the content in the Law Journal Library is constantly changing and some content has restrictions as required per the license. Therefore, please review the available content via the following link to ensure the material you wish to access is included in the database. For a complete list of content included in the Law Journal Library, please click here.

Learn More About the Law Journal Library (pdf)
Back To Top Jump To Bottom